68 In 2007, when the Commission first considered the proper classification of then-nascent mobile broadband, the Commission had a different understanding about the relationship between mobile broadband and VoIP. At that time, the Commission considered VoIP applications to be a separate, non-integrated service, such that VoIP’s ability to connect internet and telephone users was not thought to render mobile broadband an interconnected service. See 2007 Wireless Order, 22 FCC Rcd. at 5917–18 ¶ 45. But when the Commission revisited the issue nearly a decade later in the Order we now review, the Commission found that its “previous determination about the relationship between mobile broadband Internet access and VoIP applications in the context of section 332 no longer accurately reflects the current technological landscape.” 2015 Open Internet Order, 30 FCC Rcd. at 5787 ¶ 401. In particular, it concluded that VoIP applications now function as an integrated aspect of mobile broadband, rather than as a functionally distinct, separate service. The Commission therefore found that mobile broadband “today, through the use of VoIP, . . . gives subscribers the capability to communicate with all NANP endpoints.” Id. In reaching that conclusion, the Commission emphasized that “changes in the marketplace . . . highlight the convergence between mobile voice and data networks that has occurred since the Commission first addressed the classification of mobile broadband Internet access in 2007.” Id. The record before the Commission substantially supports that understanding, as well as the associated finding that the relationship between VoIP applications and mobile broadband today significantly differs from that of 2007. For instance, in 2007, Apple’s iPhone—the only device at the time even “resembling a modern smart phone”—had just been released and was available through only one mobile carrier. Letter